Mr. Sanctions

Month: December 2025

  • December 19, 2025: OFAC adds Maduro family & associates to SDN List, plus updated GL and FAQ

    Based on the OFAC Notice and related press releases for December 19, 2025:

    Venezuela-related Designations; Issuance of Venezuela-related General License; Publication of Amended Venezuela-related Frequently Asked Question

    Treasury Press Release: Treasury Targets Family Members and Associates of Maduro Regime

    Additions:

    VENEZUELA-EO13850 Executive Order 13850

    CARRETERO NAPOLITANO, Roberto, Panama; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: CARRETERO NAPOLITANO, Ramon).

    CARRETERO NAPOLITANO, Vicente Luis, Panama; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: CARRETERO NAPOLITANO, Ramon).

    FLORES DE MALPICA, Eloisa, Venezuela; Gender Female; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: MALPICA FLORES, Carlos Erik).

    HURTADO PEREZ, Damaris del Carmen, Venezuela; Gender Female; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: MALPICA FLORES, Carlos Erik).

    MALPICA FLORES, Iriamni, Venezuela; Gender Female; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: MALPICA FLORES, Carlos Erik).

    MALPICA HURTADO, Erica Patricia, Venezuela; Gender Female; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: MALPICA FLORES, Carlos Erik).

    MALPICA TORREALBA, Carlos Evelio, Venezuela; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: MALPICA FLORES, Carlos Erik).

    Supplemental Information: The Treasury Department designated these seven individuals for their roles as family members and associates helping to sustain the narco-corruption structure of the Maduro regime. Specifically, the action targets the networks of Carlos Erik Malpica Flores (a nephew of Cilia Flores and former official at PDVSA and the Venezuelan Treasury) and Panamanian businessman Ramon Carretero Napolitano. Eloisa Flores de Malpica is the mother of Carlos Erik Malpica Flores and sister of Cilia Flores. Carlos Evelio Malpica Torrealba is his father, Iriamni Malpica Flores is his sister, Damaris del Carmen Hurtado Perez is his wife, and Erica Patricia Malpica Hurtado is his adult daughter. Roberto and Vicente Luis Carretero Napolitano are immediate family members of Ramon Carretero. Malpica Flores has been previously sanctioned and linked to corruption within Venezuela’s state-run oil company, PDVSA.

    You can learn more about the sanctions process in this video: OFAC Sanctions List Search tool which explains how to verify designated individuals.

    Additionally, we have a new version of GL 5:  Venezuela-related General License 5T, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After February 3, 2026.” As usual, the date at which you can deal in the bond has been pushed out – now it’s February 3rd of next year.

    And the related Frequently Asked Question – FAQ 595 – has been updated to reflect the new GL version and the new date.

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  • December 19, 2025: OFSI updates 1 in Russia program, adds 9 to the Syria one

    Here are the reformatted Syria designations:

    Based on the OFSI Notice Syria 19/12/2025, the following entries have been added to the Consolidated List.

    Additions

    Individuals

    • Mohammed Hussein AL-JASIM
      • Group ID: 17250
      • Title: Brigadier General
      • DOB: (1) –/–/1985, (2) –/–/1987, (3) –/–/1986, (4) –/–/1988
      • POB: Jousa, Hama Governorate, Syria
      • a.k.a: AMSHA, Abu (non-Latin script: أبو عمشة)
      • Nationality: (1) Syria, (2) Turkey
      • Other Information: (UK Sanctions List Ref): SYR0420.
      • Statement of Reasons: The Secretary of State considers that there are reasonable grounds to suspect that Mohammed al-Jasim is an involved person under the Syria (Sanctions) (EU Exit) Regulations 2019 on the basis of the following ground: AL-JASIM is or has been involved in repressing the civilian population of Syria.
      • Supplemental Information: Al-Jasim, widely known as “Abu Amsha,” is the commander of the Sultan Suleiman Shah Division (also known as Al-Amshat), a faction of the Syrian National Army (SNA) operating in Turkish-controlled areas like Afrin; his group is notorious for severe human rights abuses, including extortion, kidnapping, sexual violence against Kurdish women, and looting, and has been involved in recruiting Syrian mercenaries for conflicts in Libya and Azerbaijan.
    • Sayf Al-Din BOULAD
      • Group ID: 17251
      • DOB: (1) –/–/1988, (2) –/–/1987
      • POB: Bza’ah, al-Bab District, Syria
      • a.k.a: BAKR, Abu (non-Latin script: أبو بكر)
      • Nationality: (1) Turkey, (2) Syria
      • Other Information: (UK Sanctions List Ref): SYR0421.
      • Statement of Reasons: The Secretary of State considers that there are reasonable grounds to suspect that Sayf BOULAD is an involved person under the Syria (Sanctions) (EU Exit) Regulations 2019 on the basis of the following ground: BOULAD is or has been involved in repressing the civilian population of Syria.
      • Supplemental Information: Boulad (also known as Sayf Abu Bakr) is the commander of the Hamza Division, a Syrian National Army faction implicated in arbitrary arrests, torture, and other abuses in Afrin and Ras al-Ain, and has facilitated the deployment of fighters to foreign conflicts.
    • Ghaith Suleiman DALLA
      • Group ID: 17249
      • DOB: 31/07/1971
      • POB: Beit Yashout, Latakia, Syria
      • a.k.a: (1) DALLA, Ghaith, Suleiman (non-Latin script: غيث دلة), (2) DALLA, Ghayath, Suleiman, (3) DALLA, Ghayth, Suleiman, (4) DALLA, Ghiath, Suleiman, (5) DALLA, Gyath, Suleiman
      • Nationality: Syria
      • Other Information: (UK Sanctions List Ref): SYR0419.
      • Statement of Reasons: The Secretary of State considers that there are reasonable grounds to suspect that Ghaith DALLA is an involved person under the Syria (Sanctions) (EU Exit) Regulations 2019 on the basis of the following ground: DALLA is or has been involved in repressing the civilian population of Syria.
      • Supplemental Information: A Brigadier General in the Syrian Army’s elite 4th Armoured Division (commanded by Maher al-Assad), Dalla is known as the “Lion of the 4th Division” (Ghayth al-Ghayth) and has commanded brutal military campaigns in the Damascus suburbs (Ghouta) and Idlib/Latakia fronts.
    • Miqdad Loay FATIHA
      • Group ID: 17248
      • POB: Jableh, Syria
      • a.k.a: JAAFAR, Abu
      • Nationality: Syria
      • Other Information: (UK Sanctions List Ref): SYR0418.
      • Statement of Reasons: The Secretary of State considers that there are reasonable grounds to suspect that Miqdad Fatiha is an involved person under the Syria (Sanctions) (EU Exit) Regulations 2019 on the basis of the following ground: FATIHA is or has been involved in repressing the civilian population of Syria.
      • Supplemental Information: A high-ranking military official often associated with the Syrian regime’s security apparatus and the 4th Division, linked by the EU to crimes against humanity and fueling sectarian violence.
    • Mudallal KHOURY
      • Group ID: 17255
      • DOB: 18/06/1957
      • POB: Homs, Syria
      • a.k.a: (1) KHOURI, Mudallal, (2) KHOURY, Madalal, (3) KHOURY, Mtanyus, (4) KHOURY, Mudalal, (5) KHURI, Mudallal (non-Latin script: مدلل خوري)
      • Nationality: (1) Russia, (2) Syria
      • Address: Moscow, Russia
      • Other Information: (UK Sanctions List Ref): SYR0425.
      • Statement of Reasons: The Secretary of State considers that there are reasonable grounds to suspect that Mudallal KHOURY is an involved person under the Syria (Sanctions) (EU Exit) Regulations 2019 on the basis of the following ground: KHOURY is or has been involved in activities supporting or benefitting from the regime.
      • Supplemental Information: A prominent financier and banker based in Moscow, he serves as an intermediary for the Syrian regime’s financial transactions and has been sanctioned by the US for facilitating the procurement of materials for Syria’s chemical weapons and ballistic missile programs.
    • Imad Mtanyus KHOURY
      • Group ID: 17256
      • DOB: 03/10/1964
      • a.k.a: (1) KHOURI, Imad, (2) KHOURY, Emad, (3) KHURI, Imad, (4) KHURI, Imad, Mtanyus, (5) KHURI, Mtanyus, (6) KHURY, Imad, (7) KHURY, Mtanyus (non-Latin script: عماد خوري)
      • Nationality: (1) Russia, (2) Syria
      • Other Information: (UK Sanctions List Ref): SYR0426.
      • Statement of Reasons: The Secretary of State considers that there are reasonable grounds to suspect that Imad KHOURY is an involved person under the Syria (Sanctions) (EU Exit) Regulations 2019 on the basis of the following ground: KHOURY is or has been involved in activities supporting or benefitting from the regime.
      • Supplemental Information: Brother of Mudallal Khoury and a businessman involved in the family’s financial networks; he has been designated by the EU and US for materially supporting the Syrian regime and its military activities.

    Entities

    • HAMZA DIVISION
      • Group ID: 17254
      • a.k.a: (1) al-Hamza Division, (2) Hamzat Division (non-Latin script: فرقة الحمزة)
      • Other Information: (UK Sanctions List Ref): SYR0424.
      • Statement of Reasons: The Secretary of State considers that there are reasonable grounds to suspect that the Hamza Division is an involved person under the Syria (Sanctions) (EU Exit) Regulations 2019 on the basis of the following ground: the Hamza Division is or has been involved in repressing the civilian population.
      • Supplemental Information: An armed opposition faction within the Turkish-backed Syrian National Army (SNA), the Hamza Division has been widely accused by international rights groups of war crimes, including torture, looting, and sexual violence in Kurdish-majority areas like Afrin.
    • SULTAN MURAD DIVISION
      • Group ID: 17252
      • a.k.a: (non-Latin script: فرقة السلطان مراد)
      • Other Information: (UK Sanctions List Ref): SYR0422.
      • Statement of Reasons: The Secretary of State considers that there are reasonable grounds to suspect that the Sultan Murad Division is an involved person under the Syria (Sanctions) (EU Exit) Regulations 2019 on the basis of the following ground: the Sultan Murad Division is or has been involved in repressing the civilian population.
      • Supplemental Information: A Turkmen-dominated faction of the Syrian National Army (SNA) operating in northern Syria; it has been implicated in the recruitment of child soldiers, the transfer of mercenaries to conflicts in Libya and Nagorno-Karabakh, and human rights abuses against civilians.
    • SULTAN SULEIMAN SHAH DIVISION
      • Group ID: 17253
      • Supplemental Information: Also known as Al-Amshat and led by Mohammed Hussein Al-Jasim (Abu Amsha), this SNA faction controls the Sheikh Hadid district in Afrin and is accused of running a “fiefdom” characterized by extortion, confiscation of property, and severe mistreatment of the local Kurdish population.

    and the changed Russia one:

    Based on the OFSI Notice provided (Russia, 19/12/2025), there are no additions listed in the Notice summary, only amendments.

    Amendments

    Entities

    LIMITED LIABILITY COMPANY RESPONSIBILITY OF “RBRU SPECIALIZED DEPOSITORY”

    • Group ID: 16924
    • a.k.a: LLC “RBRU SD”
    • Other Information: (UK Sanctions List Ref): RUS2682.
    • Financial sanctions imposed in addition to an asset freeze:Added: Correspondent banking relationships etc. The prohibition on correspondent banking relationships etc. measure was imposed on 19/12/2025.Trust services. Date trust services sanctions imposed: 20/05/2025.
    • (UK Statement of Reasons): Limited Liability Company responsibility of “RBRU Specialized depository” is an “involved person” under the Russia (Sanctions) (EU Exit) Regulations 2019 because it is or has been involved in obtaining a benefit from or supporting the Government of Russia by carrying on business in sectors of strategic significance to the Government of Russia, namely the Russian financial services sector.
    • (Business Reg No): 9704154155
    • Listed on: 20/05/2025 UK Sanctions List
    • Date Designated: 20/05/2025
    • Last Updated:Removed: 20/05/2025Added: 19/12/2025

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  • OFSI amends General Licence INT/2025/7628424

    Turns out the General Licence (GL) shows you when things were updated, but not what was amended. As per the email sent by OFSI, the “good stuff” is in the Publication Notice:

    Publication_Notice_Document_-_INT-2025-7628424Download

    So, going forward, I’ll give you the link to the GL, but show you the Publication Notice.

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  • Upcoming Industry Events (while my calendar is kaput)

    Google has disabled my Mr. Sanctions account, which locks me out of the calendar. In the meantime, here’s info on a few upcoming events that recently hit my inbox (titles all link to registration pages, unless otherwise noted):

    Google says the appeals process takes 2 business days. If somehow I don’t prevail, I will create a new calendar under my other Gmail account, and figure out how I want to use email for this site (the Contact page and my inbounds from regulators).

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  • Burning Question: Whither Mr. Sanctions?

    As you may know, this is a “hobby” for me: it’s fun to put together, playing with the AI tools is actually useful long-term at work, and forcing myself to keep on top of the news releases keeps me sharp. And it is just me: when I am on vacation, unless I’ve prepared some thought pieces to post, we’ll go dark (the royal We… like I said, it’s just me).

    So, I asked Gemini to scout the competition, tell me how the site compares, and what I could do to leverage the other sites’ strengths…

    Based on your request, I have analyzed Mr. Sanctions (mrsanctions.com) and identified five close analogs in the sanctions news and analysis space. Mr. Sanctions is characterized by its witty, personal tone (“Moving at the speed of the world…”), its use of AI tools (Gemini) to simplify complex regulations for “laypeople,” and its focus on timely updates from OFAC, OFSI, and Canada.

    Here are the 5 closest analogs, their comparison to Mr. Sanctions, and recommendations for improvement.

    1. European Sanctions

    URL: https://www.europeansanctions.com

    Language: English (UK/EU focus)

    Overview:

    Run by Maya Lester KC and Michael O’Kane, this is widely considered the “gold standard” for sanctions blogs. It focuses heavily on EU and UK sanctions judgments, legislation, and enforcement.

    Comparison:

    • Pros: Extremely authoritative (written by top legal experts); has a legendary search function for finding specific case law or posts; covers EU/UK listings in granular detail that US-centric blogs often miss.
    • Cons: Can be dry and highly legalistic; less “layperson-friendly” than Mr. Sanctions; lacks the humor or personal voice found on your site.

    Recommendation for Mr. Sanctions:

    Emulate the “Searchable Database” or “Resource Hub.” European Sanctions excels because it acts as a reference library, not just a news feed. Mr. Sanctions could improve by creating a dedicated, searchable “Index of General Licenses” or a “Case Law Tracker” that aggregates your simplified summaries into a permanent library, rather than just chronological posts.

    2. Sanctions.io (Blog)

    URL: https://www.sanctions.io/blog

    Language: English

    Overview:

    A corporate blog that has mastered the art of educational content. They publish “Ultimate Guides,” “Top 5 Trends,” and “What is X?” articles designed to rank high on search engines and educate beginners.

    Comparison:

    • Pros: Visually appealing with good use of headers and bullet points; excellent SEO (Search Engine Optimization); breaks down complex topics into “Guides” (e.g., “The 5 Pillars of Compliance”).
    • Cons: Clearly a marketing vehicle for their software; feels corporate and sanitized; lacks the “insider” or “curator” personality that makes Mr. Sanctions engaging.

    Recommendation for Mr. Sanctions:

    Adopt the “Guide” Structure. Mr. Sanctions already has “Burning Questions,” but could expand this into “Mr. Sanctions’ Guides.” Creating “The Layperson’s Guide to the 50% Rule” or “How to Read an SDN Entry” with your signature wit would drive long-term traffic better than daily news updates alone.

    3. Russian International Affairs Council (RIAC) / Ivan Timofeev

    URL: https://russiancouncil.ru/en/analytics-and-comments/analytics/

    Language: Russian (with English translations)

    Overview:

    This is the premier source for sanctions analysis from the target’s perspective. Analysts like Ivan Timofeev provide deep, academic, and geopolitical analysis on the impact of Western sanctions on the Russian economy and how Russia adapts.

    Comparison:

    • Pros: Offers a completely different perspective (the “other side”); deep long-form analysis that explains the why and so what of sanctions, not just the what; highly intellectual.
    • Cons: Can be dense and academic; politically charged (reflects Russian policy interests); not a quick “news update” source.

    Recommendation for Mr. Sanctions:

    Incorporate “The Target’s View.” You could introduce a recurring segment that analyzes how sanctioned jurisdictions (Russia, Iran, Venezuela) are reacting to the new designations you list. Summarizing “What Russia thinks about the new IT sanctions” using your AI tools would add a layer of geopolitical depth that most compliance blogs lack.

    4. Castellum.AI (Insights)

    URL: https://www.castellum.ai/insights

    Language: English

    Overview:

    A data-focused blog that uses charts, graphs, and statistics to visualize sanctions trends (e.g., “Sanctions by the Numbers”). They focus heavily on data quality, enforcement trends, and the intersection of AI and compliance.

    Comparison:

    • Pros: excellent use of data visualization (charts showing designation spikes); focus on “Enforcement” and “Typologies”; modern, tech-forward vibe similar to your use of Gemini.
    • Cons: Can be niche (focusing on data schema issues); less focus on the day-to-day legal interpretation of General Licenses.

    Recommendation for Mr. Sanctions:

    Visualize the Data. You mention “Canada adds a ship-ton of new guidance”—a chart showing the rise in ship designations over the last year would be powerful. Use free tools to create simple bar charts or heat maps to accompany your “Daily Digests,” making the “speed of the world” visible at a glance.

    5. OpenSanctions

    URL: https://www.opensanctions.org/articles/

    Language: English

    Overview:

    An open-source data project that blogs about the technical and transparency aspects of sanctions. They discuss how lists are built, the difficulty of matching names, and the “plumbing” of the global financial system.

    Comparison:

    • Pros: Unique angle on the technology of sanctions; very transparent and community-driven; appeals to the technical/investigative crowd (journalists, developers).
    • Cons: Very technical; appeals less to the policy/legal crowd; irregular posting schedule compared to news sites.

    Recommendation for Mr. Sanctions:

    Lean into the “Tech/AI” Angle. You already use Gemini to summarize text. You could create a “Mr. Sanctions vs. The Machine” segment where you test different AI models on compliance tasks (e.g., “I asked ChatGPT, Gemini, and Claude to explain General License 44—here’s who won”). This differentiates you as the “Sanctions Blog for the AI Era.”

    Summary of Recommendations for Mr. Sanctions

    Feature to EmulateSource InspirationActionable Idea
    Searchable IndexEuropean SanctionsCreate a “Library” page for your simplified GL summaries.
    “Ultimate Guides”Sanctions.ioWrite “The Layperson’s Guide to [Topic]” permanent pages.
    Counter-PerspectiveRIACAdd a “View from the Target” section summarizing reaction from sanctioned states.
    Data VisualsCastellum.AIAdd one chart per week (e.g., “Designations this Month”).
    AI ExperimentsOpenSanctionsA regular column testing AI tools on sanctions tasks.

    Interesting thoughts, no? These sound like weekend projects… and probably a lot more AI practice for me, since long-form content, including the research process, is not something I’ve got bandwidth for.

    Watch this space…

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  • What did Exodus Movement agree to do with its compliance program?

    Based on the OFAC enforcement release and settlement agreement regarding Exodus Movement, Inc., here is a summary of the Compliance Commitments (often found in Section 2 or labeled as a specific point in the agreement terms):

    • Sanctions Compliance Program: Exodus agrees to maintain a comprehensive sanctions compliance program for at least five years.
    • Management Commitment: The company will ensure senior management support and the provision of adequate resources to the compliance function.
    • Risk Assessment: Exodus will conduct periodic risk assessments to identify and mitigate sanctions risks specific to its business.
    • Internal Controls: The company must implement and maintain written policies and procedures, including effective sanctions screening (such as IP blocking/geoblocking) and escalation protocols for potential matches.
    • Testing and Audit: Exodus is required to perform independent testing and audits to ensure the effectiveness of its compliance program.
    • Training: The company commits to providing regular (at least annual) sanctions compliance training to relevant employees.
    • Compliance Investment: Exodus has specifically agreed to invest $630,000 in additional sanctions compliance controls and measures.
    • Reporting: A senior executive must submit annual certifications to OFAC for a period of five years, confirming that the company is meeting these compliance obligations.

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  • December 16, 2025: OFAC Settles with Exodus Movement

    What Happened

    Exodus Movement, Inc. (“Exodus”), a U.S. company that makes software wallets for digital assets, has agreed to pay $3,103,360 to settle potential violations of U.S. sanctions against Iran.

    Between October 2017 and January 2019, Exodus allowed users in Iran to use its software to manage and trade digital currency. While Exodus didn’t process the trades itself (it used third-party partners), it earned fees from the transactions.

    The main issue was that Exodus staff knew some users were in Iran—a sanctioned country—but helped them anyway. When Exodus’s partners blocked these users to comply with the law, Exodus customer support told the users to use a VPN (Virtual Private Network) to hide their location and bypass the blocks. All of this happened even though Exodus’s own rules said people in sanctioned countries couldn’t use the app, but the company didn’t have a real system in place to check or stop them.

    The Penalty

    Exodus agreed to pay $3,103,360 to resolve the matter. The total maximum possible penalty was much higher, but the final amount was reduced because Exodus cooperated and fixed the problems.

    Breakdown of Violations

    There were 254 total violations, split into two types:

    • 12 Egregious Violations: These were the most serious cases where staff actively helped users evade sanctions. The base penalty for these was calculated at the legal maximum, totaling $4,532,400.
    • 242 Non-Egregious Violations: These were the standard transaction violations where users in Iran simply used the wallet without specific evasion advice.

    Aggravating and Mitigating Factors

    OFAC determined the final penalty by weighing “Aggravating Factors” (bad behavior that raises the fine) against “Mitigating Factors” (good behavior that lowers the fine).

    Aggravating Factors

    • Helping users trick the system
      • General Factor A: Willful or Reckless Violation of Law
      • Exodus staff knew their partners had blocked Iranian users for legal reasons but willfully advised those customers to use VPNs to get around the security controls.
    • Management knew about the risks
      • General Factor A: Awareness of Conduct
      • Company leadership and staff were generally aware of U.S. sanctions and knew that their partners were restricting access to Iran, but they continued to support these users anyway.
    • Undermining the purpose of sanctions
      • General Factor D: Harm to Sanctions Objectives
      • By helping people in a sanctioned country trade digital assets, Exodus defeated the purpose of the sanctions (which is to block access to the U.S. financial system) and sabotaged the compliance work of its partners.

    Mitigating Factors

    • Clean track record
      • General Factor B: Administrative License; Prior Notice of Penalty or Penalty
      • Exodus has not received a penalty notice or a finding of violation from OFAC in the five years preceding the earliest date of the transactions.
    • Fixing the compliance program
      • General Factor F: Remedial Response
      • Exodus took serious steps to prevent this from happening again, including installing software to block users from sanctioned regions (geo-blocking) and training its staff on compliance rules.
    • Cooperating with investigators
      • General Factor G: Cooperation with OFAC
      • Exodus worked closely with OFAC during the investigation, providing documents and information that helped resolve the case efficiently.

    What are the Takeaways?

    Compliance Considerations

    • Start Early: Companies, especially startups in fintech and crypto, must build sanctions compliance into their business model from day one, not wait until they are large.
    • Don’t Help Evasion: Customer support staff should never advise users on how to bypass security controls (like suggesting VPNs). This is considered a willful violation.
    • Technology Matters: Simply having “Terms of Use” that ban sanctioned users is not enough; companies need technical controls (like IP blocking) to actually stop them.
    • Check Your Partners: If you rely on other companies (like exchanges) to provide services, ensure your compliance standards match theirs so you don’t become a loophole.

    Other resources

    For more information on how to set up a proper compliance program, OFAC recommends reviewing:

    • A Framework for OFAC Compliance Commitments: A guide on the five essential parts of a sanctions compliance program.
    • Sanctions Compliance Guidance for the Virtual Currency Industry: Specific instructions for crypto companies on how to follow U.S. sanctions laws.

    Mr. Sanctions’ Note: This settlement required some tweaking of the prompt I use to produce these summaries for the non-expert. This was for two reasons:

    • The fact that there were both egregious and non-egregious violations caused the original prompt to treat everything as non-egregious. As revised, the summary now shows the effect on the base penalty of those egregious items.
    • Probably at least partly due to the previous point, the aggravating factors list included two separate, but related, items: willful behavior in the case of the egregious violations, and reckless behavior with regard to the rest.

    Even with this, Gemini missed the (admittedly minor) mitigating factor of not having a recent enforcement history. Luckily, when I told it that it had missed it and that it should be added back, it did so.

    BTW, here are the Enforcement Release:

    20251216_exodusDownload

    and the Settlement Agreement (which you get pretty rarely – generally only when there is egregious conduct):

    20251216_exodus_settlementDownload

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  • OFAC Amends two Russia-related FAQs

    As per the OFAC Notice:

    Issuance of Amended Russia-related Frequently Asked Questions

    Release Date

    12/18/2025

    Recent Actions Body

    OFAC is issuing two amended Russia-related Frequently Asked Questions, FAQ 1224 and 1225.

    The FAQs:

    1224. What negotiations does Russia-related General License 131A authorize, and what transaction conditions will OFAC consider when evaluating requests for further authorization to effectuate a sale of Lukoil International GmbH (LIG) assets?

    Answer

    On October 22, 2025, OFAC designated PJSC Lukoil (Lukoil) to increase pressure on Russia’s energy sector and degrade Russia’s ability to raise revenue for its war machine.  OFAC is aware of potential efforts by Lukoil to divest its assets outside of Russia to non-blocked parties, given the impact of sanctions.  To support such divestments and further cut off funding to Russia, OFAC issued Russia-related General License (GL) 131A, which authorizes negotiations and entry into contingent contracts with Lukoil for the sale of LIG or any of LIG’s majority-owned subsidiaries.  Authorized activities include negotiations on terms for definitive agreements and financial, legal, or operational due diligence, including engagement of outside counsel or advisors.  GL 131A expires on January 17, 2026.

    GL 131A does not authorize transactions to effectuate the actual sale, disposition, or transfer of any LIG entity or asset.  Any contract entered into pursuant to GL 131A must expressly be made contingent upon the receipt of a separate authorization from OFAC.  The goal of OFAC’s Russia sanctions is to place pressure on Moscow to end its war. 

    As such, Treasury would evaluate any proposed sale of LIG based on factors that support U.S. national security and foreign policy objectives.  OFAC expects that, at a minimum, the proposed transaction must:  completely sever LIG’s ties with Lukoil; block any funds owed to Lukoil until sanctions are lifted by placing them in an account subject to U.S. jurisdiction; and not provide a windfall to Lukoil, such as by providing up-front value to Lukoil, including through asset or share swaps.  Further, as a condition of any future license for effectuating a sale of LIG, OFAC expects that it will require persons purchasing LIG’s assets to seek OFAC review before further divestment of material LIG assets.

    OFAC may revoke GL 131A at any time, including if Lukoil and LIG do not appear to be engaging in good faith negotiations regarding the divestment of LIG or its assets.

    Date Updated: December 18, 2025

    Date Released

    November 19, 2025

    and:

    1225. What activities do Russia-related General License 128B and General License 131A authorize related to Lukoil International GmbH (LIG)?

    Answer

    OFAC has issued two General Licenses (GLs) relating specifically to Lukoil International GmbH (LIG) and its majority-owned subsidiaries (“LIG Entities”):  GL 128B and GL 131A.  The GLs are similar but have different expiration dates and terms as each serves a different purpose.  

    • To mitigate the effects of Lukoil’s OFAC designation on retail consumers, OFAC issued on December 4, 2025 GL 128B to authorize maintenance, operation, and wind down activities for a narrow range of LIG entities, specifically Lukoil retail automobile service stations outside of the Russian Federation.  This GL expires on April 29, 2026.
    • To enable Lukoil to divest its assets outside of Russia to non-blocked parties, OFAC issued on December 10, 2025 GL 131A to authorize, among other things, maintenance and wind down activities of all LIG Entities.  This GL has a shorter duration as it expires on January 17, 2026.  Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.  

    GL 128B and GL 131A expressly authorize transactions undertaken in the ordinary course of business, provided that the transactions do not involve any blocked persons other than the LIG Entities described in GL 128B and GL 131A.  Transactions undertaken in the ordinary course of business may involve (but are not limited to):  supply of motor fuel and lubricants; lease payments; insurance payments; property maintenance and environmental services; employee payroll, benefits, severance, and reimbursements; information technology services; payments to government authorities; legal services and proceedings; payments to suppliers, landlords, lenders, and partners; the preservation and upkeep of pre-existing tangible property; and activities associated with maintaining pre-existing capital investments.  Also, both GL 128B and GL 131A authorize transactions ordinarily incident and necessary to performing pre-existing agreements and conducting intracompany transfers, provided that such transactions are consistent with previously established practices and support pre-existing projects or operations, consistent with the terms of the respective authorizations.  

    Both GL 128B and GL 131A also authorize financial institutions, payment processors, and other entities to use, debit, and credit the accounts of the relevant LIG Entities to effectuate the respective authorizations, but both GLs are also expressly limited by the condition that no funds may be transferred to a person or account in the Russian Federation.

    Non-U.S. persons generally do not risk exposure to U.S. sanctions under E.O. 14024 for engaging in transactions with blocked persons that are generally authorized for U.S. persons, including for those authorized by GL 128B and GL 131A.  Similarly, non-U.S. persons may rely upon GL 128B and GL 131A regardless of whether a foreign financial institution maintains blocked accounts, provided the non-U.S. person’s activities are consistent with the terms of GL 128B and GL 131A, including the requirement that no payments may be transferred to any person or account located in the Russian Federation. 

    Date Updated: December 18, 2025
     

    Date Released

    December 4, 2025

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  • December 18, 2025: OFAC issues Iran-related and ICC-releated GLs

    From the OFAC Notice today:

    The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing International Criminal Court-related General License 11, “Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on December 18, 2025;” and Iran-related General License S, “Authorizing Limited Safety and Environmental Transactions and the Offloading of Cargo Involving Certain Persons or Vessels Blocked on December 18, 2025.”

    and here is the ICC-related one:

    icc_gl11Download

    and the Iran-related one:

    iran_glsDownload

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  • December 18, 2025: OFAC adds to Iran, ICC sanctions, removes from Russia sanctions & an FSE designation removal

    From today’s Notice, the following additions and delistings were made:

    Iran-related Designations; International Criminal Court-related Designations; Russia-related Designations Removals; Foreign Sanctions Evaders Determination Removal; Issuance of Iran-related and International Criminal Court-related General Licenses

    Treasury Press Release:

    Treasury Increases Pressure on Iran’s Sanctions-Evading Shadow Fleet

    State Press Release:

    Sanctioning ICC Judges Directly Engaged in the Illegitimate Targeting of Israel

    Additions:

    Specially Designated Nationals List Update

    [ICC-EO14203]

    Imposing Sanctions on the International Criminal Court

    DAMDIN, Erdenebalsuren

    • Netherlands
    • DOB 07 Aug 1967
    • POB Ulaanbaatar, Mongolia
    • nationality Mongolia
    • Gender Male
    • Diplomatic Passport D00004977 (Mongolia) expires 25 Dec 2027
    • Type (individual)

    LORDKIPANIDZE, Gocha

    • Netherlands
    • DOB 03 Feb 1964
    • POB Poti, Georgia
    • nationality Georgia
    • Gender Male
    • Diplomatic Passport 10DP04141 (Georgia) expires 18 Feb 2026
    • Type (individual)

    Supplemental Information:

    According to the State Department press release, Erdenebalsuren Damdin and Gocha Lordkipanidze are International Criminal Court (ICC) judges. They were designated for directly engaging in efforts by the ICC to investigate, arrest, detain, or prosecute Israeli nationals without Israel’s consent, including voting in favor of the ICC’s ruling against Israel’s appeal.

    [IRAN-EO13902]

    Imposing Sanctions with Respect to Additional Sectors of Iran

    SAKR, Hatem Elsaid Farid Ibrahim

    AKAs: SAKR, Hatem Elsaid Farid Ibrahim (Arabic: حاتم السعید فرید ابراهیم صقر)

    • Al Mizhar 1, Dubai, United Arab Emirates
    • DOB 14 Apr 1984
    • POB Kafr El Sheikh, Egypt
    • nationality Egypt
    • Gender Male
    • Passport A28342914 (Egypt) expires 14 Jul 2028
    • Identification Number 784198495048732 (United Arab Emirates)
    • Type (individual)

    ADONIS SHIPPING INC

    • Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date 05 Apr 2024
    • Identification Number IMO 6490991
    • Registration Number 125282 (Marshall Islands)

    AGAPE SHIPPING INC

    • Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date 13 Mar 2024
    • Identification Number IMO 6483853
    • Registration Number 124804 (Marshall Islands)

    ALEAH SHIPPING INC

    • Intershore Chambers, Road Town, Tortola, Virgin Islands, British
    • Organization Established Date 2024
    • Identification Number IMO 0115648

    ARIHANT SHIPPING INC.

    • Panama City, Panama
    • Organization Established Date 29 Nov 2019
    • Identification Number IMO 6137793
    • Folio Mercantil No. 155688452 (Panama)

    CONCORD SHIPPING INC.

    • Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date 17 Sep 2021
    • Identification Number IMO 6255216
    • Registration Number 110904 (Marshall Islands)

    DARYA SHIPPING PRIVATE LIMITED

    AKAs: DARYA SHIPPING PVT LTD

    • No. 421, 422, and 423, Fourth Floor, Vipul Plaza, Golf Course Road, Gurgaon 122011, India
    • Website www.daryashipping.in
    • Organization Established Date 16 Nov 2017
    • Identification Number IMO 6017001
    • Trade License No. U74999HR2017PTC071501 (India)
    • Company Number 98450007AWFB9BFC6A06 (India)

    EVEREST SEA NAVIGATION SA

    • 80 Broad Street, Monrovia, Liberia
    • Organization Established Date 2023
    • Identification Number IMO 6452167

    GOLDEN GATE SHIP MANAGEMENT

    • Office No A-301, Mahavir Icon, CBD Belapur, Plot 89, Sector 15, Thane, Navi Mumbai, Maharashtra 400614, India
    • Organization Established Date 01 Oct 2024
    • Identification Number IMO 0029112
    • Company Number UDYAM-MH-33-0532049 (India)

    HEMERA LINES INC.

    • Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date 07 Sep 2022
    • Identification Number IMO 6358714
    • Company Number 116070 (Marshall Islands)

    HIGH SEAS PETROLEUM LLC

    AKAs: HIGH SEAS PETROLEUM LLC (Arabic: هاي سیز للنفط ذ م م), PETROFLEET ENERGY TRADING LLC, PETROFLEET ENERGY TRADING LLC (Arabic: بيتروفلييت انيرجي للتجارة ذ م م)

    • Office 102, Al Zarooni Tower, Al-Mamzar, Dubai, United Arab Emirates
    • Office No 306, Al Mamzer, Deira, Dubai, United Arab Emirates
    • Organization Established Date 15 Jul 2021
    • Identification Number IMO 6243669
    • License 968668 (United Arab Emirates)
    • Economic Register Number (CBLS) 11708243 (United Arab Emirates)Linked to: SAKR, Hatem Elsaid Farid Ibrahim

    J M A SHIPPING INC.

    • Panama City, Panama
    • Organization Established Date 27 Apr 2021
    • Identification Number IMO 6225751
    • Folio Mercantil No. 155705332 (Panama)

    KURDOS SHIPPING INC.

    • Suites D&E, 20th Floor, Global Plaza Tower, Calle 50, Panama City, Panama
    • Organization Established Date 17 Jul 2008
    • Identification Number IMO 5409641
    • Registration Number 625159 (Panama)

    M K A SHIPPING INC

    • Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date 24 May 2022
    • Identification Number IMO 6323643
    • Registration Number 114584 (Marshall Islands)

    MARUTI SHIPPING INC.

    • Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date 31 May 2024
    • Identification Number IMO 6506573
    • Registration Number 126286 (Marshall Islands)

    PHOENIX SHIP MANAGEMENT FZE

    AKAs: PHOENIX SHIP MANAGEMENT FZE (Arabic: فينيكس لإدارة السفن م م ح)

    • Office No E-39F-09, (P1-ELOB), Hamriyah Free Zone, Sharjah, United Arab Emirates
    • Website https://phoenixfze.com/
    • Organization Established Date 23 Apr 2025
    • Identification Number IMO 0226749
    • License 38883 (United Arab Emirates)

    QATRAT ALNADA ALMASI SHIP MANAGEMENT L.L.C

    • Office 604, Green Tower, Rigga Albuteen, Deira, Dubai, United Arab Emirates
    • Organization Established Date 15 Feb 2024
    • Identification Number IMO 6479652
    • Commercial Registry Number 2226924 (United Arab Emirates)
    • License 1312327 (United Arab Emirates)
    • Chamber of Commerce Number 519528 (United Arab Emirates)

    RED SEA SHIP MANAGEMENT LLC

    AKAs: RED SEA SHIP MANAGEMENT LLC (Arabic: ريد سي لإدارة السفن ذ م م)

    • Office No 306, Parcel 133-251, Al Mamzar, Deira, Dubai, United Arab Emirates
    • Organization Established Date 05 Dec 2023
    • Identification Number IMO 6454999
    • License 1272054 (United Arab Emirates)
    • Chamber of Commerce Number 503160 (United Arab Emirates)Linked to: SAKR, Hatem Elsaid Farid Ibrahim

    RUKBAT MARINE SERVICES CO

    • Unit 1905, Haware Infotech, Sector 30A, Vashi, Navi Mumbai, Maharashtra 410210, India
    • Organization Established Date 2025
    • Identification Number IMO 0156125

    S M A SHIPPING INC.

    • Office 703, 6th Floor, Centennial Center, Panama City, Panama
    • Organization Established Date 29 Jan 2021
    • Identification Number IMO 6206261
    • Folio Mercantil No. 155701731 (Panama)

    SINOSTAR MARINE GROUP LIMITED

    • Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date 19 Mar 2024
    • Identification Number IMO 0059859
    • Company Number 124911 (Marshall Islands)

    AETHER SAIL

    • Chemical/Products Tanker Palau flag
    • Vessel Year of Build 2003
    • Vessel Registration Identification IMO 9277371
    • MMSI 511101256
    • Type (vessel)Linked to: PHOENIX SHIP MANAGEMENT FZE

    ARIHANT

    • Products Tanker Palau flag
    • Vessel Year of Build 2009
    • Vessel Registration Identification IMO 9464156
    • MMSI 511100268
    • Type (vessel)Linked to: ARIHANT SHIPPING INC.

    AUROURA

    • Oil Products Tanker Panama flag
    • Vessel Year of Build 2004
    • Vessel Registration Identification IMO 9262912
    • MMSI 352001225
    • Type (vessel)Linked to: GOLDEN GATE SHIP MANAGEMENT

    DIANA

    • Crude Oil Tanker Jamaica flag
    • Vessel Year of Build 2004
    • Vessel Registration Identification IMO 9255945
    • MMSI 339000161
    • Type (vessel)Linked to: ALEAH SHIPPING INC

    FLORA DOLCE

    • Chemical/Products Tanker Barbados flag
    • Vessel Year of Build 2004
    • Vessel Registration Identification IMO 9258595
    • MMSI 314001081
    • Type (vessel)Linked to: RUKBAT MARINE SERVICES CO

    FOSHAN

    • Chemical/Products Tanker Panama flag
    • Vessel Year of Build 2007
    • Vessel Registration Identification IMO 9404572
    • MMSI 352001366
    • Type (vessel)Linked to: SINOSTAR MARINE GROUP LIMITED

    GOLDEN EAGLE

    • Crude Oil Tanker Unknown flag
    • Former Vessel Flag Gambia
    • Vessel Year of Build 2004
    • Vessel Registration Identification IMO 9255684
    • MMSI 341313001
    • Type (vessel)Linked to: EVEREST SEA NAVIGATION SA

    HEMERA

    • Asphalt/Bitumen Tanker Palau flag
    • Vessel Year of Build 2006
    • Vessel Registration Identification IMO 9263954
    • MMSI 511101408
    • Type (vessel)Linked to: HEMERA LINES INC.

    INTAN PREMIER

    • Chemical/Products Tanker Palau flag
    • Vessel Year of Build 2009
    • Vessel Registration Identification IMO 9358802
    • MMSI 511101645
    • Type (vessel)Linked to: RED SEA SHIP MANAGEMENT LLC

    J M A

    • Oil Products Tanker Cook Islands flag
    • Vessel Year of Build 2001
    • Vessel Registration Identification IMO 9246487
    • MMSI 518998202
    • Type (vessel)Linked to: J M A SHIPPING INC.

    KASSIA

    • Chemical/Products Tanker Panama flag
    • Vessel Year of Build 2008
    • Vessel Registration Identification IMO 9409986
    • MMSI 352001708
    • Type (vessel)Linked to: ADONIS SHIPPING INC

    KHADIGA

    • Chemical/Products Tanker Palau flag
    • Vessel Year of Build 2006
    • Vessel Registration Identification IMO 9321469
    • MMSI 511100904
    • Type (vessel)Linked to: RED SEA SHIP MANAGEMENT LLC

    KURDOS

    • Chemical/Products Tanker Palau flag
    • Vessel Year of Build 2001
    • Vessel Registration Identification IMO 9236731
    • MMSI 511101920
    • Type (vessel)Linked to: KURDOS SHIPPING INC.

    KURDOS II

    • Chemical/Products Tanker Palau flag
    • Vessel Year of Build 2008
    • Vessel Registration Identification IMO 9453729
    • MMSI 511101194
    • Type (vessel)Linked to: KURDOS SHIPPING INC.

    KURDOS III

    • Chemical/Products Tanker Palau flag
    • Vessel Year of Build 2008
    • Vessel Registration Identification IMO 9380570
    • MMSI 511101819
    • Type (vessel)Linked to: KURDOS SHIPPING INC.

    M K A

    • Chemical/Products Tanker Cook Islands flag
    • Vessel Year of Build 2003
    • Vessel Registration Identification IMO 9269403
    • MMSI 518998516
    • Type (vessel)Linked to: M K A SHIPPING INC

    MAJESTY

    • Chemical/Products Tanker Cook Islands flag
    • Vessel Year of Build 2012
    • Vessel Registration Identification IMO 9430715
    • Type (vessel)Linked to: CONCORD SHIPPING INC.

    MARUTI

    • Products Tanker Cook Islands flag
    • Vessel Year of Build 2010
    • Vessel Registration Identification IMO 9546710
    • MMSI 518998458
    • Type (vessel)Linked to: MARUTI SHIPPING INC.

    NEBULA DRIFT

    • Products Tanker Palau flag
    • Vessel Year of Build 2002
    • Vessel Registration Identification IMO 9233973
    • MMSI 511101749
    • Type (vessel)Linked to: PHOENIX SHIP MANAGEMENT FZE

    NOMIKI

    • Chemical/Products Tanker Panama flag
    • Vessel Year of Build 2002
    • Vessel Registration Identification IMO 9242443
    • MMSI 352004062
    • Type (vessel)Linked to: AGAPE SHIPPING INC

    RAMYA

    • Chemical/Products Tanker Barbados flag
    • Vessel Year of Build 2006
    • Vessel Registration Identification IMO 9363182
    • MMSI 314001076
    • Type (vessel)Linked to: DARYA SHIPPING PRIVATE LIMITED

    S M A

    • Asphalt/Bitumen Tanker Cook Islands flag
    • Vessel Year of Build 2003
    • Vessel Registration Identification IMO 9273002
    • MMSI 518100962
    • Type (vessel)Linked to: S M A SHIPPING INC.

    SEA CITRINE VI

    • Products Tanker Palau flag
    • Vessel Year of Build 1999
    • Vessel Registration Identification IMO 9207273
    • MMSI 511101409
    • Type (vessel)Linked to: QATRAT ALNADA ALMASI SHIP MANAGEMENT L.L.C

    SEA ROCK

    • Products Tanker
    • Former Vessel Flag Palau
    • Vessel Year of Build 1996
    • Vessel Registration Identification IMO 9140451
    • Type (vessel)Linked to: QATRAT ALNADA ALMASI SHIP MANAGEMENT L.L.C

    SEA WISE

    • Products Tanker Palau flag
    • Vessel Year of Build 2001
    • Vessel Registration Identification IMO 9224570
    • MMSI 511100774
    • Type (vessel)Linked to: QATRAT ALNADA ALMASI SHIP MANAGEMENT L.L.C

    SEAMULL

    • Products Tanker Palau flag
    • Vessel Year of Build 2001
    • Vessel Registration Identification IMO 9204776
    • MMSI 511100317
    • Type (vessel)Linked to: QATRAT ALNADA ALMASI SHIP MANAGEMENT L.L.C

    SKYLIGHT

    • Chemical/Products Tanker Palau flag
    • Vessel Year of Build 2006
    • Vessel Registration Identification IMO 9330020
    • MMSI 511101102
    • Type (vessel)Linked to: RED SEA SHIP MANAGEMENT LLC

    TIDAL RHYTHM

    • Asphalt/Bitumen Tanker Panama flag
    • Vessel Year of Build 2004
    • Vessel Registration Identification IMO 9297101
    • MMSI 352004719
    • Type (vessel)Linked to: PHOENIX SHIP MANAGEMENT FZE

    VOYAGER HAVEN

    • Chemical/Products Tanker Panama flag
    • Vessel Year of Build 2004
    • Vessel Registration Identification IMO 9271896
    • MMSI 352004496
    • Type (vessel)Linked to: PHOENIX SHIP MANAGEMENT FZE

    Supplemental Information:

    The Treasury Department has designated these entities and vessels as part of the Iranian “shadow fleet” used to evade sanctions and export Iranian petroleum and petroleum products. Hatem Elsaid Farid Ibrahim Sakr, an Egyptian businessman, is identified as a key figure managing several of these companies (Red Sea Ship Management, High Seas Petroleum) which coordinate with the Iranian Ministry of Defense-associated front company Sahara Thunder. The designated vessels have been involved in transporting hundreds of millions of dollars’ worth of Iranian petroleum products, including fuel oil, bitumen, naphtha, and condensate, often to end users in Asia.

    Delistings:

    Specially Designated Nationals List Update

    [RUSSIA-EO14024]

    Blocking Property With Respect To Specified Harmful Foreign Activities Of The Government Of The Russian Federation

    VELES INTERNATIONAL LIMITED, Globe House, Floor No. 5, 23 Kennedy, Nicosia 1075, Cyprus; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Organization Established Date 21 Sep 2005; Tax ID No. 10165706H (Cyprus); Identification Number M9DR4T.99999.SL.196 (Cyprus); Legal Entity Number 213800HFBG8GID98ID84; Registration Number C165706 (Cyprus) (Linked To: BUGAYENKO, Dmitry Vitalyevich).

    HADLERCO LIMITED, Marilena Building, Flat No 101, No 1, Prigkipissas Zinas Kanther 12, Nicosia 1065, Cyprus; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Organization Established Date 11 Aug 2000; Tax ID No. 10113889S (Cyprus); Legal Entity Number 213800MRUA23SZCWPO15; Registration Number C113889 (Cyprus) (Linked To: BUGAYENKO, Dmitry Vitalyevich).

    BUGAYENKO, Dmitry Vitalyevich (a.k.a. BUGAENKO, Dmitrii Vitalyevich; a.k.a. BUGAENKO, Dmitry), 6/1 Michurinsky Prospekt, 187-188, Moscow 119295, Russia; DOB 15 Dec 1966; POB Moscow, Russia; nationality Russia; alt. nationality Cyprus; Gender Male; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Passport K00148307 (Cyprus) issued 26 Sep 2013 expires 26 Sep 2023; National ID No. 1274836 (Cyprus) (individual).

    BUGAENKO, Dmitry (a.k.a. BUGAENKO, Dmitrii Vitalyevich; a.k.a. BUGAYENKO, Dmitry Vitalyevich), 6/1 Michurinsky Prospekt, 187-188, Moscow 119295, Russia; DOB 15 Dec 1966; POB Moscow, Russia; nationality Russia; alt. nationality Cyprus; Gender Male; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Passport K00148307 (Cyprus) issued 26 Sep 2013 expires 26 Sep 2023; National ID No. 1274836 (Cyprus) (individual).

    BUGAENKO, Dmitrii Vitalyevich (a.k.a. BUGAENKO, Dmitry; a.k.a. BUGAYENKO, Dmitry Vitalyevich), 6/1 Michurinsky Prospekt, 187-188, Moscow 119295, Russia; DOB 15 Dec 1966; POB Moscow, Russia; nationality Russia; alt. nationality Cyprus; Gender Male; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Passport K00148307 (Cyprus) issued 26 Sep 2013 expires 26 Sep 2023; National ID No. 1274836 (Cyprus) (individual).

    DREMOVA, Evgenia, Finland; DOB 26 Aug 1977; nationality Finland; Gender Female; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Identification Number 260877 (Finland) (individual).

    HI-TECH KONEISTO INTERNATIONAL OY, Hirsalantie 11, Jorvas 02420, Finland; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Organization Established Date 21 Jul 2021; V.A.T. Number FI32114731 (Finland); Identification Number 3211473-1 (Finland) (Linked To: DREMOVA, Evgenia).

    365 DAYS FREIGHT SERVICES FZCO, Warehouse No. F24, Dubai Airport Free Zone, PO Box 99083, Dubai, United Arab Emirates; Secondary sanctions risk: See Section 11 of Executive Order 14024.; License 1303 (United Arab Emirates); Economic Register Number (CBLS) 11436269 (United Arab Emirates).

    ETASIS ELEKTRONIK TARTI ALETLERI VE SISTEMLERI SANAYI VE TICARET ANONIM SIRKETI (a.k.a. ETASIS A.S.), 2001 Cadde No 36, 75, Yil Mahallesi, Odunpazari 26250, Turkey; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Tax ID No. 7838098822 (Turkey); Registration Number 26355 (Turkey).

    ETASIS A.S. (a.k.a. ETASIS ELEKTRONIK TARTI ALETLERI VE SISTEMLERI SANAYI VE TICARET ANONIM SIRKETI), 2001 Cadde No 36, 75, Yil Mahallesi, Odunpazari 26250, Turkey; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Tax ID No. 7838098822 (Turkey); Registration Number 26355 (Turkey).

    CPS PROSES KONTROL URUNLERI SANAYI VE TICARET ANONIM SIRKETI, Carsi Yapi Sitesi G Blok, No: 10G/5 Sanayi Mahallesi, Kocaeli, Turkey; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Organization Established Date 22 Feb 2022; Tax ID No. 2150603096 (Turkey); Business Registration Number 32873 (Turkey).

    Foreign Sanctions Evaders List Update

    [FSE-IR]

    Foreign Sanctions Evaders (FSE) – Iran

    KAYAKIRAN, Evren, Turkey; DOB 08 Feb 1980; citizen Turkey; Gender Male; Passport U00242309 (Turkey) (individual).

    I will cover the General Licenses in a separate post (and work on the prompt so I don’t lose the formatting in the deletions section).

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